PRIVACY POLICYVenan Entertainment, Inc.
This Privacy Policy is effective as of February, 2013

About Venan Entertainment, Inc.

Venan Entertainment, Inc. (“Venan”, "we," "us" or "our") is a premier developer and publisher
of mobile games, including, Book of Heroes™, Super Putt™, Ninjatown: Trees of Doom™, Space Miner® and others (individually a “Game” and collectively, the “Games”) for use with a variety of portable platforms and mobile and wireless devices, including the iPhone, iPad, and Android devices.

1. Your Privacy

We understand that your privacy is important to you. Venan is committed to protecting our users' information and to making sure our users are aware of our practices regarding the privacy and security of their information. We want you to understand what information we collect from users of our website located at www.venan.com (the “Site”) and in connection with our Games, how we handle that information and how you can contact us to correct any information that we may have collected.

2. What This Privacy Policy Entails

This Privacy Policy guides our collection, storage and use of information, including personally-identifiable and non-personally identifiable information, collected at our Site, when you download our Games or use our Games. By accessing the Site, downloading our Games or using our Games, you expressly consent and agree to the terms and conditions of this Privacy Policy, including our use and disclosure of any personally-identifiable information and non-personally-identifiable information in accordance with this Privacy Policy. If you do not agree, then please do not use or access the Site or download or use our Games.

You also agree that any user that accesses our Site, or downloads or uses our Games agrees that (i) such user is at least eighteen years old and has agreed to this Privacy Policy; or (ii) such user is between the ages of thirteen and eighteen and that such user, and such user’s parent or legal guardian, have each agreed to this Privacy Policy.

3. Personally-Identifiable Information of Children Under the Age of 13

Our Site and our Games are not intended for children under the age of 13. Therefore, Venan does not knowingly solicit or collect personally-identifiable information from children under the age of 13. If Venan learns that a child under the age of 13 has submitted
personally-identifiable information to us, in contravention of these measures, it will take all reasonable measures to delete such information from its servers and databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law).

4. Changes to This Privacy Policy

Any or all of this Privacy Policy may be changed at any time without notice to you and your use of the Site, or the downloading or use of our Games following any such change will mean you accept such changes. Therefore, each time you access or use our Site, download or use any of our Games, you should review this Privacy Policy.

We will post our revised Privacy Policy on our Site, and in connection with our Games, and may provide you with notice of any changes by e-mail at the e-mail address you provide to us through our Site or through our Games. For this reason, you should make sure that you maintain a current e-mail address with us.

If you download our Games from iTunes, Google Play or other third party platforms or sites you should review, read and accept their Terms of Use and Privacy Policies.

5. Contact Us About Our Privacy Policy

Should you have any questions about our Privacy Policy please contact us by writing to Mr. Brandon Curiel at Venan Entertainment, Inc., 162 West Street, Suite F, Cromwell, CT 16416, by email at: privacy@venan.com or by phone at 860-632-9738.

6. Information We Collect From You

Venan only collects personally-identifiable and non-personally identifiable information to the extent reasonably necessary for legitimate business purposes, and in connection with our users’ use of the Site, the downloading of our Games and the use of our Games, in accordance with this Privacy Policy.

A. From Users of the Site, Venan Collects:

Personally-identifiable information you voluntarily disclose to us in any content you submit or disclose it to us, including through the Support Form on our Site, through our blog on our Site, by email or phone. Such information includes your e-mail address or other information you include in the questions, comments or explanations you submit to us about an issue or concern you have with one of our Games, or otherwise.

SPECIAL NOTICE: Any information you reveal or post on our blog is made public to others, is not protected by this Privacy Policy and may be shared with third parties – whether by us or by other users of the blog or our Site. Accordingly you should not post any information on our blog that you do not want shared with others.

Non-personally identifiable information you voluntarily disclose to us in any content you submit or disclose to us, including through the Support Form on our Site, through our blog on our Site, by email or phone. Such information may include your mobile platform type, the OS version of the software you are using or your mobile device type.

We may also collect certain information from your browser, including domain names, IP addresses, browser information, operating system information, or information on what users access, utilize or visit on or through the Site.

SPECIAL NOTICE: We Collect Non-personally Identifiable Information from the Site Using Google Analytics.

Google Analytics is a web analytic service offered by Google Inc. ("Google"). Google Analytics uses "cookies" which are elements of data that a website can send to a user’s browser and store on a user’s computer. Cookies can note that a user’s browser was used to visit certain sites or pages on a certain date. Venan uses Google Analytics to enhance navigation and functionality of the Site, and to let it know how visitors are using the Site, so that it can improve the Site or a user’s experience on it.

The information about your usage of websites collected through these cookies is transmitted to and stored on Google’s servers.

You may opt out of the use of cookies by configuring your own browser settings directly to handle cookies. The “help” menu on most browsers will explain how you can decline cookies. However, there is no guarantee that by doing so you will have access to all of the features on our Site. You may also prevent the cookies from collecting and storing
non-personally identifiable information by downloading and installing the browser-plugin at: http://tools.google.com/dlpage/gaoptout?hl=en.

You acknowledge and agree that Google Analytics may combine the information collected with other information it has independently collected from other services or products relating to your activities. Google Analytics collects and uses information under its own terms of use and privacy policies which you should carefully review.

How the Information We Collect From the Site is Used

Venan may use the information you give it to provide services to you and to other users in connection with use of the Site and our Games.

We may use the content you submit to us via the Site (for example on our Support Form), by e-mail, our blog on the Site, or otherwise, in a variety a ways to enhance our delivery of our Games and services to you and to others, including reposting your customer support requests or issues (with any personal-identifiers removed from the posting) that you submit to us via the Support Form on the Site.

We may use the information we collect from your browser to improve our Site, to personalize your experience or offer additional features or information. We may also use this information to analyze our Site and its usage.

B. From Users of Our Games, Venan Collects:

Personally-identifiable information voluntarily provided by you such as your e-mail address when you register for our Games, or your email address and other content you decide to submit when you sign up for and use our forums or guilds, post messages about yourself or to other Games users, use our “chat” feature to chat with other Game users, compose emails to other Game users within our Games or recruit or invite friends to play our Games.

SPECIAL NOTICE: Any information you reveal or post in our public forums or guilds or to other Games users is not protected by this Privacy Policy and may be shared with third parties – whether by us or other Game users also utilizing these features of our Games. Accordingly you should not post any information that you do not want shared with others.

SPECIAL NOTICE:Registering for our Games is not required to play our Games.

However, doing so allows you to have access to special features such as Game scores and Game score history, Game play history, communicating with other Game users, posting messages to other Game users, unlocking multiple character slots or accessing your characters and heroes across multiple mobile and wireless devices.

Information Collected at Registration - Should you register for our Games, at the time of registration we will collect your email address. We also request that you choose a “display name” by which other Game users can see you as and create a password.

Venan does not see, store or have access to your password.The display name you choose is an anonymous name that does not identify you. Should you wish to change your display name you may do so by utilizing the options in our Games or by emailing us at: privacy@venan.com.

If you do not register with us, we may assign you a “display name”. However, because Venan offers a communal gaming experience, we will disclose your “display name” and scores to other Game users. We do not allow other Game users to use any of this information outside of our Games

Emails From You to Recruit Other Game Users - Should you wish to send an email to a friend to “recruit” or invite them to play our Games, we will collect and store your friend’s email address on our servers. These email addresses are stored separately from the information we collect from our existing Game users. Venan does not use such email addresses for marketing or for any other purpose, nor are they shared with third-parties. However, when you submit the email addresses of other individuals to us, you thereby agree, represent and warrant to us in each instance that you have obtained consent from each such individual to the submission of such email address.

Downloading Additional Features. You may be given the option to download additional features in connection with our Games, namely, to enable HD graphics. In so doing, we do not collect any personally-identifiable information from you.

Non-personally identifiable information that we track and store about Game users, such as their game play, their purchase of virtual equipment, their “energy” used during game play, interactions with other Game players, mobile device information, including unique device IDs or other device identifiers, mobile carrier providers, mobile operating systems, device manufactures, software versions of devices, and geo-location information when you download or play our Games. None of this information allows us to directly identify you.

We collect such non-personally identifiable information through the use of third party metrics and analytics tools. You acknowledge and agree that the third-party metrics and analytics companies utilized by Venan may combine the information collected with other information they have independently collected from other services or products relating to your activities. These companies collect and use information under their own terms of use and privacy policies which you should carefully review.

SPECIAL NOTICE: Venan utilizes the services of the following third party metrics and analytics companies:Apsalar by Apsalar, Inc. which is visitor identification technology that, as applicable, collects, transmits, maintains, processes and uses anonymous traffic data.Mobile App Tracking by HasOffers, Inc. which is technology that tracks the installs of some of our Games on mobile phones and wireless devices such as Android and Apple iOS for iPhones and iPads.
You may opt-out of HasOffers, Inc.’s analytics tracking by clicking the link provided in their Privacy Agreement posted on www.mobileapptracking.com/privacy-policy/ or by emailing optout_mat@hasoffers.com and including your mobile device identifier.

How the Information We Collect from Users of our Games is Used:

Venan may use the information you give it to provide services to you and to other users in connection with use of our Games.

The personally-identifiable information we collect from you during the registration process is used for authentication purposes and to personalize your subsequent Game play.

We may use your email address to assist you when you need to reset and create a new password. We may also email you referral codes which you can provide to prospective Game users to invite them to try our Games.

We may use any content or communications you submit to us or post in connection with our Games, including in our forums and guilds or to other Game users, in a variety of ways for legitimate business purposes and/or to enhance our delivery of our Games and services to you.

We may use the information we collect when you use or download our Games to improve our Games, to personalize your experience or offer additional features or information. We may also use this information to analyze our Games and their usage.

7. Use of YouTube, Twitter or Facebook to Gain Access to Us

You may see previews of or information about our Games on YouTube, subscribe to our Twitter feed or become a fan of our Facebook page for up to date information on new Games and other exciting announcements from us. YouTube, Twitter or Facebook may collect personally-identifiable information from you in accordance with their own Terms of Use and Privacy Polices. Youshould review, read and accept their Terms of Use and Privacy Policies as it relates to the collection of your personally-identifiable information associated with these activities.

8. How Long We Keep Your Personally-Identifiable Information

Venan only retains the personally-identifiable information you provide as it as reasonably necessary for you to use our Games, or for us to provide customer support or other services described herein in connection with our Games.

Only authorized users are permitted to see this information. Such users are advised by us of the need for keeping your personally-identifiable information confidential.

9. Opt-Out

At any time, should you wish for us to no longer communicate with you, or wish to have us delete or destroy any email addresses, content or communications you send to us, please write to us at Venan Entertainment, Inc., 162 West Street, Suite F, Cromwell, CT 16416, ATTN: Mr. Brandon Curiel or send an email to: privacy@venan.com.

You may also refrain from using Game features that collect specific types of data such as your e-mail address, or ask for content such as suggestions and feedback.

At any time, if you no longer wish to use our Games, simply delete or uninstall our Games from your mobile phone or wireless device using the removal features on such phone or device. Once you have uninstalled the Games, all information they may have stored is deleted, and all push notifications (if you have elected to receive any) will stop.

10. Push Notifications

If you permit us to, we may send you push notifications to your mobile phone and wireless device to provide you with Game alerts, sounds and icon badges which may enhance Game play. You may manage and configure your push notifications from the settings option on your mobile or wireless device.

11. External Distribution of Personally-Identifiable Information and of Confidential Information

Venan does not externally distribute personally-identifiable information that is provided by users of our Site and our Games, except if a Site or Game user specifically opts-in that certain of its personally-identifiable information may be distributed to a third party or if necessary to protect the rights of Venan or other Site or Game users.

Further, external distribution does not include certain limited distributions such as sharing personally-identifiable information with a third party working on behalf of Venan, the transfer of personally-identifiable information in connection with the sale of Venan’s assets or the merger of Venan or the disclosure of personally-identifiable information in connection with legal proceedings, investigations of crimes, or other governmental investigations. Transferring personally-identifiable information in connection with a sale or merger and sharing personally-identifiable information with an entity or person working on behalf of Venan is considered an Onward Transfer to third parties and will be handled as described below.

12. OnwardTransfer

Venan shall only make Onward Transfers of personally-identifiable information provided by a user of the Site or our Games (i) in connection with a sale of assets of Venan or a merger involving Venan or (ii) to a third party working on behalf of or providing services to Venan. Any such Onward Transfer shall be limited to third parties that (i) subscribe to the safe harbor principles of the U.S. Department of Commerce or are subject to the European Commission’s Directive on Data Protection, or (ii) have entered into a written agreement with Venan requiring that such third party provides at least the same level of privacy protection as is required by such safe harbor principles.

13. Venan Does Not Share Your Personally-Identifiable Information.

We respect your privacy and understand the need to keep it as confidential as possible. We do not share any personally-identifiable information that we collect from you, either via the Site or in connection with the download and use of our Games, with any third-parties including marketing firms for marketing purposes.

However, as noted in Sections 11 and 12 above, we may disclose your information to third-party service providers when employing other companies and individuals to perform functions on our behalf. Examples include sending postal mail and e-mail, analyzing data and providing customer service. These service providers have access to personally-identifiable information needed to perform their functions, but such service providers may not use personally-identifiable information for other purposes.

14. Venan May Share Your Non-Personally Identifiable Information
Venan may share or disclose non-personally identifiable information, whether aggregated or otherwise, with third parties for purposes of analyzing the usage of the Site and our Games, or for managing, providing and further developing the Site and our Games, or as otherwise deemed necessary by Venan.

15. Use of Cookies

Venan utilizes third party analytic technologies such as Google Analytics which uses cookies. Additionally, some of our Third Party Advertisers for our Games may utilize cookies. For more information on how to disable cookies see Section 5A of this Privacy Policy.

16. Security

Venan uses industry accepted reasonable safeguards to protect the security, integrity and privacy of personally-identifiable information provided to Venan by users of the Site and of its Games, including encryption technologies to encrypt your passwords.

Venan only retains the personally-identifiable information you provide as it is reasonably necessary for you to play our Games and to enhance your gaming experience.

Once we store your personally-identifiable information, only authorized users are permitted to see this information and these users are advised by us of the need for keeping your personally-identifiable information confidential. The servers that store such information are not available to the public.

ALTHOUGH VENAN TAKES (AND WILL REQUIRE OUR THIRD-PARTY PROVIDERS TO TAKE) REASONABLE SECURITY PRECAUTIONS WITH RESPECT TO YOUR PERSONALLY-IDENTIFIABLE INFORMATION COLLECTED FROM AND STORED ON THE SITE, OUR SERVERS OR OUR GAMES, VENAN CANNOT GUARANTEE THAT ANY OF YOUR PERSONALLY-IDENTIFIABLE INFORMATION STORED ON THE SITE, OUR SERVERS OR OUR GAMES, OR TRANSMITTED TO OR FROM THE SITE, YOUR MOBILE PHONE OR WIRELESS DEVICE OR OUR GAMES, WILL BE FREE FROM UNAUTHORIZED ACCESS. TO THE FULLEST EXTENT PERMITTED BY LAW, VENAN DISCLAIMS AND SHALL HAVE NO LIABILITY FOR ANY LOSS OF, UNAUTHORIZED ACCESS OR DAMAGE TO, OR INTERCEPTION OF ANY OF YOUR PERSONALLY-IDENTIFIABLE INFORMATION BEING TRANSMITTED TO OR FROM THE SITE, OUR GAMES, OR STORED ON THE SITE, OUR SERVERS, OR OUR GAMES OR WHEN YOU DOWNLOAD OUR GAMES TO OR PLAY THEM ON A MOBILE PHONE OR WIRELESS DEVICE.

17. How to Access, Review and Change Your Personally-Identifiable Information
Users of our Site and our Games can, by e-mailing Venan Entertainment Inc. at privacy@venan.com, access, review and correct the personally-identifiable information that has been collected from them by Venan.

Users should also report to us via such e-mail address any improper collection or misuse of information provided on the Site or our Games.

Users may, where applicable, correct such personally-identifiable information that is collected in connection with our Games by making changes to their profiles themselves using the passwords created by them.

18. Third Party Advertisers

We may use outside companies to display ads in connection with our Games such as third-party Offer Wall providers (see more under the Offer Wall section below). These ads and notices may contain cookies. Additionally, once you click on a third-party ad, you will be directed away from our Game. The display ads are not under the control of Venan and Venan is not responsible for the content of any such display ad.

19. Offer Walls

Venan may provide Offer Walls within its Games whereby users click on third-party advertisements and in return purchase virtual currency to obtain energy, virtual equipment to outfit your characters (such as swords and other protective gear), and enhance, extend and provide other options in connection with our Games.

These Offer Walls are not provided by Venan but by third-party Offer Wall providers such as W3i, LLC which collects and uses information from you under its own terms of use and privacy policies which can be viewed at this link: http://policy.w3i.com/privacypolicy.html

Once you click on a third-party advertisement, you will be directed away from our Games. The third-party advertisements are not under the control of Venan and Venan is not responsible for the content of any such third-party advertisements, their payment processes or methods or the handling of your billing and payment information. Venan does not process your payments or see any of your billing or payment information. If you decide to access any of the third party advertisements, you do this entirely at your own risk.

20. Governing Law; Jurisdiction and Waiver of Jury Trial

By accessing the Site and by downloading and playing our Games, you agree that the laws of the State of Connecticut, without regard to principles of conflict of laws, will govern this Privacy Policy and any dispute of any sort that might arise between you and us, including without limitation any tort claims. Any such dispute shall be adjudicated in any state court in Connecticut, or any federal court in Connecticut, and you consent to exclusive jurisdiction and venue in such courts. YOU AND WE EXPRESSLY AGREE HEREBY, TO THE FULLEST EXTENT PERMITTED BY LAW, TO WAIVE THE RIGHT TO A TRIAL BY JURY.

21. Binding Agreement; Changes

By accessing the Site and downloading and playing our Games, you agree that any dispute with respect to privacy is subject to this Privacy Policy, the Terms of Use of the Site and the Terms of Use and License Agreement for our Games, including without limitation the provisions therein regarding the governing law and jurisdiction designation with respect to any dispute regarding the Site and our Games, your use of the Site and the downloading and playing of our Games, any content you submit to us, any content on our Site or on our Games, our collection and use of personally-identifiable information as stated herein, and the limitation on damages stated therein as to any and all claims that may be asserted by you as a user of the Site or our Games for any and all causes of action that you may seek to assert.